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Industrial Emissions LicenceApplication P1033-02: GrangeBackUp Power LimitedReview of BAT Conclusions from CommissionImplementing Decision 2017/1442

14 November 2017

Grange BackUp Power Limited

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229349512 05 Ahttps://mottmac-my.sharepoint.com/personal/mark_mccarthy_mottmac_com/Documents/Grange/GrangeBack Up Power EPA RFI Response.docxMott MacDonald

Mott MacDonaldSouth BlockRockfieldDundrumDublin 16 D16 R6V0Ireland

T +353 (0)1 2916 700mottmac.com

Grange BackUp PowerLimitedc/o Synergy Global,3015 Lake Drive,City West,Dublin 24.

Industrial Emissions LicenceApplication P1033-02: GrangeBackUp Power LimitedReview of BAT Conclusions from CommissionImplementing Decision 2017/1442

14 November 2017

Directors: C O’Donovan BE MBA CEngMIET (Managing), J T Murphy BEHDipMM CEng FIEI CMCILT (DeputyManaging), D Herlihy BE MSc CEng, KHowells BSc MBA CEng MICE MCIWEM(British), F McGivern BSc DipEnvEngCEng MIEIInnealtoirí Comhairleach (ConsultingEngineers)Company Secretary: Ian Kilty BA (Hons)ACARegistered in Ireland no. 53280. MottMacDonald Ireland Limited is a member ofthe Mott MacDonald Group

Grange BackUp Power Limited

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Mott MacDonald | Industrial Emissions Licence Application P1033-02: Grange BackUp Power LimitedReview of BAT Conclusions from Commission Implementing Decision 2017/1442

229349512 | 05 | A | 14 November 2017

Issue and Revision Record

Revision Date Originator Checker Approver DescriptionA 14 Nov

2017M McCarthy P Brennan P Kelly BAT Update

Document reference: 229349512 | 05 | A

Information class: Standard

This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose.

We accept no responsibility for the consequences of this document being relied upon by any other party, or beingused for any other purpose, or containing any error or omission which is due to an error or omission in data suppliedto us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to otherparties without consent from us and from the party which commissioned it.

This r epo rt h as b een pre par ed s olely fo r us e by the par ty which co mmissio ned i t (t he ‘Clien t’) in conn ectio n with t he c aptio ned pr oject. I t sho uld not b e us ed f or a ny o the r pu rpos e. N o pe rson oth er t han the Clie nt o r a ny pa rty w ho h as ex pres sly ag ree d te rms of r elianc e with us (t he ‘Re cipien t(s)’ ) m ay r ely on the cont ent, i nfo rma tion or a ny views exp resse d in t he rep ort. W e acc ept no d uty o f ca re, resp onsibility or lia bility to any oth er recipie nt of this docu men t. This r epo rt is c onfid ential and cont ains p rop riet ary in tellect ual p rop erty .

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Mott MacDonald | Industrial Emissions Licence Application P1033-02: Grange BackUp Power LimitedReview of BAT Conclusions from Commission Implementing Decision 2017/1442

229349512 | 05 | A | 14 November 2017

Contents

1 Background 1

2 General BAT Conclusions 2

3 Operation on Gas Oil 10

4 Operation on Natural Gas 16

Appendices 19

A. General BAT Conclusions: Additional Information 20

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Mott MacDonald | Industrial Emissions Licence Application P1033-02: Grange BackUp Power Limited 1Review of BAT Conclusions from Commission Implementing Decision 2017/1442

229349512 | 05 | A | 14 November 2017

1 Background

Grange Backup Power Ltd. proposes to construct a 96 MW dual fuel fired power plant on agreenfield site in Grange Castle Business Park, Clondalkin, Dublin 22.

The power plant falls under the following class of activity as defined in the First Schedule of theEnvironmental Protection Act 1992, as amended:

Class 2.1: Combustion of fuels in installations with a total rated thermal input of 50 MW or more.

The power plant is designed to use natural gas as the main fuel. However, in order to complywith Commission for Regulation of Utilities (CRU)1 regulations, low sulphur gas oil will be storedas a backup fuel in the event of interruption to the natural gas supply. Up to 72 hours (3 days)maximum running capacity of this secondary operations fuel is required to be stored on site in abunded tank. It should be noted however that the power plant is expected to operate primarilyon natural gas and only in very rare circumstances on gas oil in the event of emergencyscenarios, an interruption to gas supplies, or testing to demonstrate such capability.

The plant received an Industrial Emissions Licence (P1033-01) from the EnvironmentalProtection Agency (EPA) in January 2017. An application for a licence review was submitted tothe EPA in May 2017. The licence review was required to take account of a reduction incapacity of the plant from 115MW to 96MW; the removal of 1 dual fired engine; alteration to theoperational hours of the facility from 12 hours to 24 hours per day; and other minor designchanges.

On the 22nd September the EPA wrote to Grange Backup Power to request that information bepresented as part of the licence review application process to demonstrate how the proposedplant will operate in the context of the applicable conclusions from the BAT Conclusions forlarge combustion plants from Commission Implementing Decision 2017/1442. The remainder ofthis report sets out how the plant will operate in the context of the following applicable BATconclusions:

● General BAT Conclusions (1 -17);● Operation on Gas Oil (31 – 35); and● Operation on Natural Gas (40, 43-45).

1 Formerly Commission for Energy Regulation (CER)

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2 General BAT Conclusions

Table 1: Environmental Management SystemsBAT 1 Analysis of Power Plant

in Context of BATBATCompliant

In order to improve the overall environmental performance, BAT is toimplement and adhere to an environmental management system(EMS) that incorporates all of the following features:

A site specific EnvironmentalManagement System (EMS)

will be developed andimplemented at the facility.

The EMS will provide theframework for environmental

management, compliance withappropriate regulatoryrequirements and theimplementation of the

principles of continuousimprovement. The

implementation of the EMS willinclude regular cross-

functional managementreviews and will be subject to

both internal and externalaudits to ensure fullcompliance with the

requirements of (i) to (xvi)contained within BAT 1 and/or

otherwise as required in thedischarge of conditions

specified in the IndustrialEmissions Licences to be

issued by the EPA.

Yes

(i) commitment of the management, including seniormanagement

(ii) definition, by the management, of an environmentalpolicy that includes the continuous improvement ofthe environmental performance of the installation

(iii) planning and establishing the necessary procedures,objectives and targets, in conjunction with financialplanning and investment

(iv) implementation of procedures paying particularattention to:

(a) structure and responsibility(b) recruitment, training, awareness and competence(c) communication(d) employee involvement(e) documentation(f) effective process control(g) planned regular maintenance programme(h) emergency preparedness and response(i) safeguarding compliance with environmental legislation

(v) checking performance and taking corrective action,paying particular attention to:

(a) monitoring and measurement(b) corrective and preventive action(c) maintenance of records(d) independent (where practicable) internal and externalauditing in order to determine whether or not the EMS conformsto planned arrangements and has been properly implementedand maintained.

(vi) review, by senior management, of the EMS and itscontinuing suitability, adequacy and effectiveness

(vii) following the development of cleaner technologies

(viii) consideration for the environmental impacts from theeventual decommissioning of the installation at thestage of designing a new plant, and throughout itsoperating life including;

(a) avoiding underground structures(b) incorporating features that facilitate dismantling(c) choosing surface finishes that are easily decontaminated(d) using an equipment configuration that minimises trappedchemicals and facilitates drainage or cleaning(e) designing flexible, self-contained equipment that enablesphased closure(f) using biodegradable and recyclable materials wherepossible.

(ix) application of sectoral benchmarking on a regularbasis. Specifically for this sector, it is also important toconsider the following features of the EMS, describedwhere appropriate in the relevant BAT:

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BAT 1 Analysis of Power Plantin Context of BAT

BATCompliant

(x) quality assurance/quality control programmes toensure that the characteristics of all fuels are fullydetermined and controlled (see BAT 9);

(xi) management plan in order to reduce emissions to airand/or to water during other than normal operatingconditions, including start-up and shutdown periods(see BAT 10 and BAT 11);

(xii) a waste management plan to ensure that waste isavoided, prepared for reuse, recycled or otherwiserecovered, including the use of techniques given inBAT 16

(xiii) a systematic method to identify and deal with potentialuncontrolled and/or unplanned emissions to theenvironment, in particular:

(xiv) a dust management plan to prevent or, where that isnot practicable, to reduce diffuse emissions fromloading, unloading, storage and/or handling of fuels,residues and additives

(xv) a noise management plan where a noise nuisance atsensitive receptors is expected or sustained,including;

(a) a protocol for conducting odour monitoring(b) where necessary, an odour elimination programme to

identify and eliminate or reduce the odour emissions(c) a protocol to record odour incidents and the appropriate

actions and timelines(d) a review of historic odour incidents, corrective actions and

the dissemination of odour incident knowledge to theaffected parties

(xvi) for the combustion, gasification or co-incineration ofmalodourous substances, an odour management planincluding:

(a) a protocol for conducting odour monitoring(b) where necessary, an odour elimination programme to

identify and eliminate or reduce the odour emissions(c) a protocol to record odour incidents and the appropriate

actions and timelines(d) a review of historic odour incidents, corrective actions and

the dissemination of odour incident knowledge to theaffected parties.

Where an assessment shows that any of the elements listed underitems x to xvi are not necessary, a record is made of the decision,including the reasons.

Table 2: MonitoringBAT BAT Description Analysis of Power Plant

in Context of BATBAT

CompliantBAT 2 BAT is to determine the net electrical efficiency and/or

the net total fuel utilisation and/or the net mechanicalenergy efficiency of the gasification, IGCC and/or

combustion units by carrying out a performance test atfull load, according to EN standards, after the

commissioning of the unit and after each modificationthat could significantly affect the net electrical efficiency

and/or the net total fuel utilisation and/or the netmechanical energy efficiency of the unit. If EN standards

are not available, BAT is to use ISO, national or other

The design, procurementinstallation and testing of thepower plant will comply with

the relevant industry standards(IS, EN etc.).

The plant will have anelectrical efficiency of 47%

which will be monitoredcontinuously.

Yes

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BAT BAT Description Analysis of Power Plantin Context of BAT

BATCompliant

international standards that ensure the provision of dataof an equivalent scientific quality.

BAT 3 BAT is to monitor key process parameters relevant foremissions to air and water including those indicated in

Appendix A.1.

The plant will monitoremissions in accordance with

this BAT requirement orotherwise as stipulated in theIndustrial Emissions Licence

issued by the EPA.

Yes

BAT 4 BAT is to monitor emissions to air with at least thefrequency given in Appendix A.2 and in accordance withEN standards. If EN standards are not available, BAT isto use ISO, national or other international standards that

ensure the provision of data of an equivalent scientificquality.



issued by the EPA.

Yes

BAT 5 BAT is to monitor emissions to water from flue-gastreatment with at least the frequency given in Appendix

A.3 and in accordance with EN standards. If ENstandards are not available, BAT is to use ISO, national

or other international standards that ensure the provisionof data of an equivalent scientific quality.



issued by the EPA.

Yes

BAT 6 In order to improve the general environmentalperformance of combustion plants and to reduce

emissions to air of CO and unburnt substances, BAT isto ensure optimised combustion and to use an

appropriate combination of the techniques given inAppendix A.4.

The plant will ensureoptimised combustion in

accordance with this this BATrequirement or otherwise as

stipulated in the IndustrialEmissions Licence issued by

the EPA.

Yes

BAT 7 In order to reduce emissions of ammonia to air from theuse of selective catalytic reduction (SCR) and/orselective non-catalytic reduction (SNCR) for the

abatement of NOX emissions, BAT is to optimise thedesign and/or operation of SCR and/or SNCR (e.g.

optimised reagent to NOX ratio, homogeneous reagentdistribution and optimum size of the reagent drops).

The power plant water willoptimise water injection and

Selective Catalytic Reduction(SCR) for NOx control.

Yes

BAT 8 In order to prevent or reduce emissions to air duringnormal operating conditions, BAT is to ensure, by

appropriate design, operation and maintenance, that theemission abatement systems are used at optimal

capacity and availability.

The plant will reduceemissions in accordance with

this this BAT requirement orotherwise as stipulated in theIndustrial Emissions Licence

issued by the EPA.

Yes

BAT 9 In order to improve the general environmentalperformance of combustion and/or gasification plantsand to reduce emissions to air, BAT is to include the

following elements in the quality assurance/qualitycontrol programmes for all the fuels used, as part of the

environmental management system (see BAT 1):

(i) Initial full characterisation of the fuel usedincluding at least the parameters listed

below and in accordance with ENstandards. ISO, national or other

international standards may be usedprovided they ensure the provision of

data of an equivalent scientific quality;(ii) Regular testing of the fuel quality to

check that it is consistent with the initialcharacterisation and according to the

plant design specifications. Thefrequency of testing and the parameterschosen from the table below are based

on the variability of the fuel and anassessment of the relevance of pollutant

The plant will include qualityassurance/quality control

programmes in accordancewith this this BAT requirement

or otherwise as stipulated inthe Industrial Emissions

Licence issued by the EPA.

Yes

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BATCompliant

releases (e.g. concentration in fuel, flue-gas treatment employed);

(iii) Subsequent adjustment of the plantsettings as and when needed and

practicable (e.g. integration of the fuelcharacterisation and control in the

advanced control system.Initial characterisation and regular testing of the fuel

can be performed by the operator and/or the fuelsupplier. If performed by the supplier, the full resultsare provided to the operator in the form of a product(fuel) supplier specification and/or guarantee as set

out in Appendix A.5.

BAT 10 In order to reduce emissions to air and/or to water duringother than normal operating conditions (OTNOC), BAT is

to set up and implement a management plan as part ofthe environmental management system (see BAT 1),

commensurate with the relevance of potential pollutantreleases, that includes the following elements:

- Appropriate design of the systems consideredrelevant in causing OTNOC that may have an

impact on emissions to air, water and/or soil(e.g. low-load design concepts for reducing

the minimum start-up and shutdown loads forstable generation in gas turbines),

- set-up and implementation of a specificpreventive maintenance plan for these

relevant systems,- review and recording of emissions caused by

OTNOC and associated circumstances andimplementation of corrective actions if

necessary,- periodic assessment of the overall emissions

during OTNOC (e.g. frequency of events,duration, emissions quantification/estimation)

and implementation of corrective actions ifnecessary

A site specific EnvironmentalManagement System (EMS)

will be developed andimplemented at the facility.

The EMS will provide theframework for environmental

management, compliance withappropriate regulatoryrequirements and theimplementation of the

principles of continuousimprovement. The

implementation of the EMS willinclude regular cross-

functional managementreviews and will be subject to

both internal and externalaudits to ensure full

compliance with this BATrequirement and/or otherwise

as required in the discharge ofconditions specified in the

Industrial Emissions Licencesto be issued by the EPA.

Yes

BAT 11 BAT is to appropriately monitor emissions to air and/or towater during OTNOC..

Air and water emissions will bemonitored as per the

requirements of this BAT. Inaddition, the following should

be noted;Air

The stack will incorporate anin-situ proprietary ContinuousEmission Monitoring System,

CEMS. The CEMS willcontinuously monitor CO

emissions from the facility inaccordance with the

requirements of the IndustrialEmissions Licence.

Surface water run offSurface water will be collected

from two catchment areaswithin the site.

The western catchmentincludes the pavement in the

vicinity of the fuel oil unloadingbay and pumped surface

water discharge from the oilstorage tank bund. Although

the fuel storage tank is located

Yes

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BATCompliant

within a bunded area,rainwater which falls here is

likely to be clean in theabsence of an oil spill or leak.

As a result, a sump andpumping arrangement located

within the bund will allow cleanrainwater to be pumped intothe collection system when

required. Pumping will bemanually activated and willpass through a Class 1 full

retention Enviroceptor to avoidpumping contaminated water.

Run-off from other pavedareas and roof area (e.g.workshop) will also drain

through the Class 1Enviroceptor.

The eastern catchmentconsists mostly of the engine

house and pavement areaswhich will drain through a

Bypass Separator.The Class 1 Enviroceptor andthe Bypass Separators will be

fitted with visual and audiblealarms to ensure containment

facilities are adequatelymaintained. In addition, this

alarm will be linked to auto dialfacilities such that relevant

staff can be alerted.There is potential for fuel or

water to spill in the hot box ofthe gas engine. The spilledliquids will be collected anddrained by gravity from the

engine through the dirty fuelconnection. Dirty leak fuel willbe led to a sludge tank whichwill be disposed of offsite by

an appropriately licencedcontractor.

The western and easterncatchment areas will have

their own surface waterattenuation tanks. The western

catchment attenuation tank(SW2) will have a storagevolume of 128m³ and the

eastern catchment attenuationtank (SW1) will have a storage

capacity of 233m³. Thesetanks have been designed to

accommodate a 1:100 yearstorm event and will discharge

via hydro-brakes to theexisting surface water

drainage system within theGrange Castle Business Parkbefore ultimately discharging

the attenuation pond in theBusiness Park.

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BATCompliant

Effluents from WaterTreatment

It should be noted that thefeedwater supply for the

demineralised water will betaken from the public water

mains. This feedwater will bepurified (demineralised) for

injection into the engine duringthe combustion process to

control NOx emissions. Thewastewater from this process

will consist of effluent from theion exchange process. This

waste water will containconcentrated dissolved solids.

Approximately 0.5m³/hr ofwastewater will be generated

from the water treatmentprocess. This wastewater will

be directed to an undergroundprocess waste water

discharge tank for monitoringand pre-treatment (at SE2).

The discharge tank will bedivided into a number of

chambers. The initial chamberwill allow balancing of the

process wastewater prior tothe effluent passing into two

aeration chambers where airwill be circulated through the

effluent to reduce thetemperature and re-aerate the

wastewater. Followingaeration the effluent passesinto a chamber where pH is

measured and dosed asnecessary with conditioning

chemicals to adjust the pH tobetween 6-9. The wastewater

will then be pumped into thedischarge chamber where it

will be monitored for pH,temperature, Biological

Oxygen Demand (BOD),Dissolved Oxygen, Suspended

Solids, Nitrate, Ammonia,Chloride, TPH, Total

Phosphorus and Conductivity.Process wastewater whichexceeds the emission limit

values specified in the licencewill not be discharged to the

existing Grange CastleBusiness Park foul drainage

system and will be recirculatedas appropriate for further

treatment.The foul drainage system from

the Business Park ultimatelydischarges to the Ringsend

Wastewater Treatment Plant(WwTP). This WwTP includes

preliminary (includingscreening/grit removal),

primary treatment, sludge

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BATCompliant

treatment, secondarytreatment (sequencing batch

reactor) and tertiary treatment(ultra violet treatment during

bathing season) and operatesunder a discharge licence from

the EPA (D0034-01).Cooling Water

The proposed cooling systemis a closed loop radiator

system not consuming anywater or producing any wastewater. As such this section of

the BAT is not relevant.

BAT 12 In order to increase the energy efficiency of combustion,gasification and/or IGCC units operated ≥ 1 500 h/yr,

BAT is to use an appropriate combination of thetechniques given in Appendix A.6.

The plant will ensureoptimised combustion in

accordance with this this BATrequirement or otherwise as


the EPA

Yes

BAT 13 In order to reduce water usage and the volume ofcontaminated waste water discharged, BAT is to useone or both of the techniques given in Appendix A.7.

The gas engine technologyhas a very low water demandcompared to other gas engine

or gas turbine technologies.This demand is approximately

0.822m3/hr. In addition, theproposed cooling system is a

closed loop radiator systemnot consuming any water orproducing any waste water.

Yes

BAT 14 In order to prevent the contamination of uncontaminatedwaste water and to reduce emissions to water, BAT is to

segregate waste water streams and to treat themseparately, depending on the pollutant content.

DescriptionWaste water streams that are typically segregated and

treated include surface run-off water, cooling water, andwaste water from flue-gas treatment.

Refer response to BAT 11.Wastewater streams will be

segregated.

Yes

BAT 15 In order to reduce emissions to water from flue-gastreatment, BAT is to use an appropriate combination of

the techniques given in Appendix A.8, and to usesecondary techniques as close as possible to the source

in order to avoid dilution.

The plant will reduceemissions in accordance with


issued by the EPA

Yes

BAT 16 In order to reduce the quantity of waste sent for disposalfrom the combustion and/or gasification process and

abatement techniques, BAT is to organise operations soas to maximise, in order of priority and taking into

account life-cycle thinking:(a) waste prevention, e.g. maximise the proportion of

residues which arise as by-products;(b) waste preparation for reuse, e.g. according to the

specific requested quality criteria;(c) waste recycling;

(d) other waste recovery (e.g. energy recovery), by implementing an appropriate combination of

techniques as set out in Appendix A.9:

The plant will reduce thequantity of waste in

accordance with this BATrequirement or otherwise as


the EPA

Yes

BAT 17 In order to reduce noise emissions, BAT is to use one ora combination of the techniques given in Appendix A.10.

The plant will reduce noiseemissions in accordance with

this BAT requirement orotherwise as stipulated in the

Yes

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BATCompliant

Industrial Emissions Licenceissued by the EPA

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3 Operation on Gas Oil

3.1 Energy Efficiency

BAT 31 - energy efficiency levels (BAT-AEELs) for the combustion of HFO and/or gas oilin reciprocating engines

Type of combustionunit

BAT-AEELs Analysis ofPower Plant

in Context ofBAT

BATCompliant

Net electrical efficiency (%) - -New unit Existing Unit -

HFO- and/or gas-oil-firedreciprocating engine —single cycle

41,5–44,5 38,3-44,5 The power plantwill have an

efficiency rateof 47% so

exceeds BAT

Yes

3.2 NOX, CO and volatile organic compound emissions to air

BAT 32 - to prevent or reduce NOX emissions to air from the combustion of HFO and/orgas oil in reciprocating engines, BAT is to use one or a combination of the techniquesgiven below.

Technique Applicability Analysis of Power Plant inContext of BAT

BAT Compliant

a Low-NOxcombustion

concept indiesel engines

Generally applicable The power plant water willoptimise water injection for NOx

control. Water injection will beemployed when the plant isoperating on distillate fuel.

Water will be injected directlyinto the combustion chamber.

The evaporation of waterrequires heat which is then not

available to heat the flamedecreasing the flame

temperature and reducing theamount of NOx produced.

Yes

b Exhaust-gasrecirculation

(EGR)

Not applicable to four-stroke engines N/A N/A

c Water/steamaddition

Applicable within the constraints ofwater availability.

The applicability may be limitedwhere no retrofit package is

available

Refer (a) above Yes

d Selectivecatalytic

reduction(SCR)

Not applicable to combustion plantsoperated < 500 h/yr.

There may be technical andeconomic restrictions for retrofitting

existing combustion plants operatedbetween 500 h/yr and 1 500 h/yr.

Retrofitting existing combustionplants may be constrained by the

availability of sufficient space


Selective Catalytic Reduction(SCR) for NOx control when

operating on natural gas.However, it is not proposed to

use SCR when operating on itssecondary fuel, distillate oil. As

previously advised to the EPA insupport of the licence application

No

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Technique Applicability Analysis of Power Plant inContext of BAT

BAT Compliant

for P1022-01, EirGrid’s GridCode states that power plants

must have a primary andsecondary fuel (as a back-up).

However, operation on thesecondary fuel would only be

required in very extremecircumstances such as in the

event of an interruption to gassupplies. For a plant such asGrange Power, the Operator

might test a couple of times ayear on the secondary fuel.

Each test might run for an houror less. As such, it would be

expected that for testingpurposes the plant would not

operate more than 10 hours perannum, and probably less. To

allow for SCR to be used whenoperating on its secondary fuel

would mean larger and moreexpensive SCR units would

need to be employed on the twoexhaust stacks proposed at

Grange. In financial terms theuse of SCR is the most

expensive control abatementtechnology for NOx control. One

unit (noting that two areproposed) may have a capitalcost of up to €350,000 and anannual operating cost of up to€56,000. To facilitate a larger

unit for operating on thesecondary fuel (less than 10hours per annum) this would

potentially result in doubling thecapital and operating costs.

Given the expected operatinghours on the secondary fuel theprovision of SCR abatement is

not considered BAT.

BAT 33 - to prevent or reduce emissions of CO and volatile organic compounds to airfrom the combustion of HFO and/or gas oil in reciprocating engines, BAT is to use one orboth of the techniques given below.Technique Description Applicability Analysis of Power Plant in

Context of BATBAT Compliant

a.

Combustionoptimisation

- Generally applicable The plant will operate on anadvanced computerised control

system which will ensureoptimum combustion conditions

and high boiler performance thatsupport the reduction of

emissions. The use of advancedmaterials, good plant and

combustion chamber design, theuse of high performance

monitoring and process controltechniques, and maintenance of

the combustion system willfurther minimise the potential for

CO emissions.

Yes

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Technique Description Applicability Analysis of Power Plant inContext of BAT

BAT Compliant

b.

Oxidationcatalysts

Not applicable tocombustion plants

operated < 500 h/yr.The applicability may

be limited by thesulphur content of the

fuel

The SCR NOX abatementsystem is combined with an

oxidation catalyst as part of thecombined NOx and CO control

system.

Yes

BAT 33 - associated emission levels (BAT-AELs) for NOX emissions to air from thecombustion of HFO and/or gas oil in reciprocating engines

Combustionplanttotalratedthermalinput(MWth)

BAT-AELs (mg/Nm3) Analysis of PowerPlant in Context of

BAT

BAT Compliant

Yearly average Daily average or averageover the sampling period

- -

Newplant

Existing

plant

Newplant

Existing plant - -

≥ 50 115–190

125–625

145–300 150–750 As indicated in theoriginal licence

application for P1022-01, this plant will

operate on gas oil onlyin very extreme

circumstances such asin the event of an

interruption to gassupplies. As such, it

would be costprohibitive to include

abatement technology(i.e. SCR) for

operation on gas oil.NOx emissions of

2000mg/nm3 wouldonly be realised during

testing of the plantwhich would be

expected to be nomore than 10 hours

per annum, andprobably less.

No

3.3 SOX, HCl and HF emissions to air

BAT 34 - in order to prevent or reduce SOx, HCl and HF emissions to air from thecombustion of HFO and/or gas oil in reciprocating engines, BAT is to use one or acombination of the techniques given below.

Technique Description

Applicability Analysis of PowerPlant in Context of

BAT

BAT Compliant

a Fuelchoice

Applicable within theconstraints associated with

the availability of differenttypes of fuel, which may be

impacted by the energypolicy of the Member State

Although the power plantwill normally be fuelled by

natural gas it is arequirement of the CRU

that a secondary fuelsource be stored on site so

that the plant can operatein the case of an

Yes

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Technique Description

Applicability Analysis of PowerPlant in Context of

BAT

BAT Compliant

interruption or loss of thenatural gas supply. In

accordance with the CRUDecision Paper Secondary

Fuelling Obligations onLicensed Generation

Capacity in the Republic ofIreland (2009),

approximately 2895m³ oflow sulphur distillate fuel

oil will be stored on site ina bunded vertical

cylindrical steel tank. Thiswill be sufficient to operate

the plant at maximumoutput for approximately

72 hours although asdiscussed previously

operation on thesecondary fuel would only

be required in veryextreme circumstances

such as in the event of aninterruption to gas

supplies.

b Ductsorbent

injection(DSI)

There may be technicalrestrictions in the case of

existing combustion plantsNot applicable to

combustion plantsoperated < 500 h/yr

DSI is not required giventhis plant will operate on

gas oil only in veryextreme circumstances


supplies.

No

c Wet flue-gas

desulphurisation (wet

FGD)

There may be technicaland economic restrictionsfor applying the technique

to combustion plants of< 300 MWth.


operated < 500 h/yr.There may be technical

and economic restrictionsfor retrofitting existing

combustion plantsoperated between 500 h/yr

and 1 500 h/yr

FGD is not required giventhis plant will operate on

gas oil only in veryextreme circumstances


supplies.

No

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BAT 34 - associated emission levels (BAT-AELs) for SO2 emissions to air from thecombustion of HFO and/or gas oil in reciprocating engines

Combustionplant totalratedthermalinput(MWth)

BAT-AELs for SO2 (mg/Nm3) Analysis ofPower Plant in

Context of BAT

BAT Compliant

Yearly average Daily average oraverage over thesampling period

- -

Newplant

Existingplant

Newplant

Existingplant

- -

All sizes 45–100

100–200 60–110

105–235 The maximumpredicted SO2

emission will be70mg/nm3

Yes

3.4 Dust and particulate-bound metal emissions to air

BAT 35 - in order to prevent or reduce dust and particulate-bound metal emissions fromthe combustion of HFO and/or gas oil in reciprocating engines, BAT is to use one or acombination of the techniques given below.

Technique Description Applicability Analysis of Power Plantin Context of BAT

BAT Compliant

a. Fuelchoice

- Applicable within theconstraints associatedwith the availability ofdifferent types of fuel,

which may be impacted bythe energy policy of the

Member State

Although the power plant willnormally be fuelled by

natural gas it is arequirement of the CRU thata secondary fuel source be

stored on site so that theplant can operate in the

case of an interruption orloss of the natural gas

supply. This will be sufficientto operate the plant at

maximum output forapproximately 72 hoursalthough as discussed

previously operation on thesecondary fuel would only

be required in very extremecircumstances such as in

the event of an interruptionto gas supplies. For a plantsuch as Grange Power, the

Operator might test a coupleof times a year on the

secondary fuel. Each testmight run for an hour or less.

As such, it would beexpected that for testing

purposes the plant would notoperate more than 10 hours

per annum, and probablyless.

Yes

b. Electrostatic

precipitator (ESP)


operated < 500 h/yr

ESP is not required giventhis plant will operate on gas

oil only in very extremecircumstances such as in

the event of an interruptionto gas supplies.

No

c. Bag filter Bag filters are not requiredgiven this plant will operate

No

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Technique Description Applicability Analysis of Power Plantin Context of BAT

BAT Compliant

on gas oil only in veryextreme circumstances such

as in the event of aninterruption to gas supplies.

BAT 35 - associated emission levels (BAT-AELs) for dust emissions to air from thecombustion of HFO and/or gas oil in reciprocating engines

Combustionplant totalratedthermalinput(MWth)

BAT-AELs for dust (mg/Nm3) Analysis of PowerPlant in Context of

BAT

BAT Compliant

Yearly average Daily average or averageover the sampling period

- -

Newplant

Existingplant

Newplant

Existing plant - -

≥ 50 5–10 5–35 10–20 10–45 As indicated in theoriginal licence

application for P1022-01, this plant will

operate on gas oil onlyin very extreme

circumstances such asin the event of an

interruption to gassupplies. Dust

emissions of30mg/nm3 would be

realised during testingof the plant which

would be expected tobe no more than 10

hours per annum, andprobably less.

No

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4 Operation on Natural Gas

4.1 Energy Efficiency

BAT 40 - associated energy efficiency levels (BAT-AEELs) for the combustion of naturalgas

Combust-ion unit

BAT-AEELs Analysis ofPower Plant in

Context of BAT

BAT Compliant

Net electricalefficiency (%)

Nettotalfuel

utilisation (%)

Net mechanicalenergy efficiency

(%)

- -

Newunit

Existingunit

Newunit

Existingunit

- -

Gasengine

39,5 -44

35–44 56–85 No BAT-AEEL. The power plant willhave an efficiency

rate of 47% soexceeds BAT

Yes

4.2 NOX, CO, NMVOC and CH4 emissions to air

BAT 43 - to use one or a combination of the techniques given below to prevent or reduceNOX emissions to air from the combustion of natural gas in engines

Technique Description Applicability Analysis of PowerPlant in Context of

BAT

BAT Compliant

a Advancedcontrolsystem

This technique isoften used in

combination withother techniquesor may be used

alone forcombustion plants

operated< 500 h/yr

The applicability to oldcombustion plants may

be constrained by theneed to retrofit the

combustion systemand/or control

command system

The plant will operate on anadvanced computerised

control system which willensure optimum

combustion conditions thatsupport the reduction of

emissions.

Yes

b Lean-burnconcept

Generally used incombination with

SCR

Only applicable to newgas-fired engines

The power plant is a dualfuel engine capable of

operating on both naturalgas and distillate oil and

will work according to thelean burn Otto-cycle which

involves compressionignition to burn fuel.

Yes

c Advancedlean-burn

concept

Only applicable to newspark plug ignited

engines

See above Yes

d Selectivecatalytic

reduction(SCR)

Retrofitting existingcombustion plants may

be constrained by theavailability of sufficient

space.Not applicable to

combustion plantsoperated < 500 h/yr.

There may be technicaland economic


SCR for NOx control whenoperating on natural gas.

Yes

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Technique Description Applicability Analysis of PowerPlant in Context of

BAT

BAT Compliant

restrictions forretrofitting existingcombustion plantsoperated between

500 h/yr and1 500 h/yr

BAT 44 – BAT is to ensure optimised combustion and/or to use oxidation catalysts toprevent or reduce CO emissions to air from the combustion of natural gas

Technique Description Analysis of PowerPlant in Context of

BAT

BAT Compliant

ReduceCOemissions

In order to prevent or reduce COemissions to air from thecombustion of natural gas, BATis to ensure optimisedcombustion and/or to useoxidation catalysts.

BAT for the control of CO emissionsis optimisation of the combustion

process. CO is a product ofincomplete combustion due to

inefficient mixing of the fuel andcombustion air, short residence

times and low combustiontemperatures. As the formation

mechanisms of NOx and CO aresimilarly influenced by combustion

temperatures it is critical thatoptimum conditions are employed.

In accordance with BAT the plant willoperate on an advanced

computerised control system whichwill ensure optimum combustion

conditions and high boilerperformance that support the

reduction of emissions. The use ofadvanced materials, good plant and

combustion chamber design, the useof high performance monitoring and

process control techniques, andmaintenance of the combustionsystem will further minimise the

potential for CO emissions.

Yes

BAT 44 - associated emission levels (BAT-AELs) for NOX emissions to air from thecombustion of natural gas in boilers and engines

Typeofcombustionplant

BAT-AELs (mg/Nm3) Analysis of PowerPlant in Context ofBAT

BATCompliant

Yearly average Daily average oraverage over thesampling period

- -

Newplant

Existingplant

Newplant

Existingplant

- -

Engine 20–75 20–100 55–85 55–110 The power plant will havean electrical output of96MW. The maximum NOX

emissions to air from thecombustion of natural gaswill be 75 mg/Nm3

Yes

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BAT 44 – Average CO emission levelsTechnique Description Analysis of Power Plant in

Context of BATBAT Compliant

COemissions

As an indication, the yearlyaverage CO emission levels

will generally be:● < 5–40 mg/Nm3 for existingboilers operated ≥ 1 500 h/yr;

● < 5–15 mg/Nm3 for newboilers;

● 30–100 mg/Nm3 for existingengines operated ≥ 1 500 h/yr

and for new engines.

The power plant will operate morethan 1500 h/yr and the maximumCO emissions will be100 mg/Nm3

Yes

BAT 45 – associated ELVs for formaldehyde and CH4 emissions to air from thecombustion of natural gas in spark ignited lean burn gas engines

Combustionplant totalrated thermalinput (MWth)

BAT-AELs (mg/Nm3) Analysis of PowerPlant in Context

of BAT

BAT Compliant

Formaldehyde

CH4 - -

Average over the samplingperiod

- -

New orexisting

plant

Newplant

Existingplant

- -

≥ 50 5–15 215–500

215–560 During its operationthe plant will ensure

optimum combustionconditions and high

boiler performance toensure compliance

with these BATrequirements.

Yes

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Appendices

A. General BAT Conclusions: Additional Information 20

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A. General BAT Conclusions: AdditionalInformation

A.1 BAT 3: Key process parameters relevant for emissions to air and water

Stream Parameter(s) MonitoringFlue-gas Flow Periodic or continuous

determination

Oxygen content, temperature, andpressure

Periodic or continuousmeasurement

Water vapour content (3)

Waste water from flue-gastreatment

Flow, pH, and temperature Continuous measurement

A.2 BAT 4: Monitor emissions to air with at least the frequency given belowSubstance/Parameter

Fuel/Process/Typeof combustion

plant

Combustion plant total

ratedthermal

input

Standard(s) (4)

Minimum monitoringfrequency (5)

Monitoringassociated

with

NH3 — When SCRand/orSNCR isused

All sizes Generic ENstandards

Continuous (6) (7) BAT 7

NOX — Coal and/orlignite

includingwaste co-

incineration

— Solidbiomass

and/or peatincluding

waste co-incineration

— HFO- and/orgas-oil-firedboilers and

engines

— Gas-oil-firedgas turbines

— Natural-gas-fired boilers,engines, and

turbines

— Iron andsteel

processgases

— Processfuels from

the chemicalindustry


Continuous (6) (8) BAT 20BAT 24BAT 28BAT 32BAT 37BAT 41BAT 42BAT 43BAT 47BAT 48BAT 56BAT 64BAT 65BAT 73

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Substance/Parameter


plant


ratedthermal

input

Standard(s) (4)



with

— IGCC plants

— Combustionplants onoffshore

platforms

All sizes EN 14792 Once every year (9) BAT 53

N2O — Coal and/orlignite in

circulatingfluidised bed

boilers

— Solidbiomass

and/or peatin circulatingfluidised bed

boilers

All sizes EN 21258 Once every year (10) BAT 20BAT 24

CO — Coal and/orlignite

includingwaste co-

incineration

— Solidbiomass




engines


— Natural-gas-fired boilers,engines, and

turbines

— Iron andsteel

processgases


the chemicalindustry

— IGCC plants


Continuous (6) (8) BAT 20BAT 24BAT 28BAT 33BAT 38BAT 44BAT 49BAT 56BAT 64BAT 65BAT 73

— Combustionplants onoffshore

platforms


SO2 — Coal and/orlignite

All sizes Generic ENstandards and

EN 14791

Continuous (6) (11) (12)

BAT 21BAT 25

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Substance/Parameter


plant


ratedthermal

input

Standard(s) (4)



with

includingwaste co-

incineration

— Solidbiomass



— HFO- and/orgas-oil-fired

boilers


engines


— Iron andsteel

processgases


the chemicalindustry in

boilers

— IGCC plants

BAT 29BAT 34BAT 39BAT 50BAT 57BAT 66BAT 67BAT 74

SO3 — When SCRis used

All sizes No ENstandardavailable

Once every year —

Gaseous chlorides,expressed as HCl

— Coal and/orlignite



boilers

All sizes EN 1911 Once every threemonths (6) (13) (14)

BAT 21BAT 57

— Solidbiomass

and/or peat


Continuous (15) (16) BAT 25

— Waste co-incineration


Continuous (6) (16) BAT 66BAT 67

HF — Coal and/orlignite



boilers


Once every threemonths (6) (13) (14)

BAT 21BAT 57

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Substance/Parameter


plant


ratedthermal

input

Standard(s) (4)



with

— Solidbiomass

and/or peat


Once every year BAT 25



Continuous (6) (16) BAT 66BAT 67

Dust — Coal and/orlignite

— Solidbiomass

and/or peat


boilers

— Iron andsteel

processgases



boilers

— IGCC plants


engines



EN 13284-1and

EN 13284-2

Continuous (6) (17) BAT 22BAT 26BAT 30BAT 35BAT 39BAT 51BAT 58BAT 75



EN 13284-2

Continuous BAT 68BAT 69

Metals andmetalloids exceptmercury (As, Cd,Co, Cr, Cu, Mn, Ni,Pb, Sb, Se, Tl, V,Zn)


— Solidbiomass

and/or peat


engines

All sizes EN 14385 Once every year (18) BAT 22BAT 26BAT 30


< 300 MWth

EN 14385 Once every sixmonths (13)

BAT 68BAT 69

≥ 300 MWth

EN 14385 Once every threemonths (19) (13)

— IGCC plants ≥ 100 MWth

EN 14385 Once every year (18) BAT 75

Hg < 300 MWth

EN 13211 Once every threemonths (13) (20)

BAT 23

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Substance/Parameter


plant


ratedthermal

input

Standard(s) (4)



with


includingwaste co-

incineration

≥ 300 MWth

Generic ENstandards and

EN 14884

Continuous (16) (21)

— Solidbiomass

and/or peat



with solidbiomass

and/or peat

All sizes EN 13211 Once every threemonths (13)

BAT 70

— IGCC plants ≥ 100 MWth

EN 13211 Once every year (23) BAT 75

TVOC — HFO- and/orgas-oil-fired

engines



boilers

All sizes EN 12619 Once every sixmonths (13)

BAT 33BAT 59


with coal,lignite, solid

biomassand/or peat


Continuous BAT 71

Formaldehyde — Natural-gasin spark-

ignited lean-burn gas

and dual fuelengines


Once every year BAT 45

CH4 — Natural-gas-fired engines

All sizes EN ISO 25139 Once every year (24) BAT 45

PCDD/F — Processfuels from


boilers


All sizes EN 1948-1,EN 1948-2,EN 1948-3

Once every sixmonths (13) (25)

BAT 59BAT 71

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A.3 BAT 5: Monitor emissions to water from flue-gas treatment with at least thefrequency given below

Substance/Parameter Standard(s) Minimummonitoringfrequency

Monitoringassociated with

Total organic carbon(TOC) (26)

EN 1484 Once every month BAT 15

Chemical oxygen demand(COD) (26)

No EN standard available

Total suspended solids (TSS) EN 872

Fluoride (F–) EN ISO 10304-1

Sulphate (SO4 2–) EN ISO 10304-1

Sulphide, easily released (S2–)

No EN standard available

Sulphite (SO3 2–) EN ISO 10304-3

Metals and metalloids As Various EN standards available(e.g. EN ISO 11885 or

EN ISO 17294-2)Cd

Cr

Cu

Ni

Pb

Zn

Hg Various EN standards available(e.g. EN ISO 12846 or

EN ISO 17852)

Chloride (Cl–) Various EN standards available(e.g. EN ISO 10304-1 or

EN ISO 15682)

—

Total nitrogen EN 12260 —

A.4 BAT 6: To ensure optimised combustion and to use an appropriatecombination of the techniques given below

Technique Description Applicabilitya.

Fuel blendingand mixing

Ensure stable combustion conditionsand/or reduce the emission of pollutants by

mixing different qualities of the same fueltype

Generally applicable

b.

Maintenance ofthe combustion

system

Regular planned maintenance according tosuppliers' recommendations

c.

Advancedcontrol system

See description in Section 8.1 The applicability to old combustion plants maybe constrained by the need to retrofit the

combustion system and/or control commandsystem

d.

Good design ofthe combustion

equipment

Good design of furnace, combustionchambers, burners and associated devices

Generally applicable to new combustion plants

e.

Fuel choice Select or switch totally or partially toanother fuel(s) with a better environmental

profile (e.g. with low sulphur and/ormercury content) amongst the availablefuels, including in start-up situations or

when back-up fuels are used

Applicable within the constraints associatedwith the availability of suitable types of fuel with

a better environmental profile as a whole,which may be impacted by the energy policy of

the Member State, or by the integrated site'sfuel balance in the case of combustion of

industrial process fuels.

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Technique Description ApplicabilityFor existing combustion plants, the type of fuelchosen may be limited by the configuration and

the design of the plant

A.5 BAT 9: Characterisation and regular testing of the fuel can be performedby the operator and/or the fuel supplier

Fuel(s) Substances/Parameters subject to characterisationBiomass/peat — LHV

— moisture

— Ash

— C, Cl, F, N, S, K, Na

— Metals and metalloids (As, Cd, Cr, Cu, Hg, Pb, Zn)

Coal/lignite — LHV

— Moisture

— Volatiles, ash, fixed carbon, C, H, N, O, S

— Br, Cl, F

— Metals and metalloids (As, Cd, Co, Cr, Cu, Hg, Mn, Ni, Pb, Sb, Tl, V, Zn)

HFO — Ash

— C, S, N, Ni, V

Gas oil — Ash

— N, C, S

Natural gas — LHV

— CH4, C2H6, C3, C4+, CO2, N2, Wobbe index

Process fuels from the chemicalindustry (27)

— Br, C, Cl, F, H, N, O, S


Iron and steel process gases — LHV, CH4 (for COG), CXHY (for COG), CO2, H2, N2, total sulphur, dust,Wobbe index

Waste (28) — LHV

— Moisture

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Fuel(s) Substances/Parameters subject to characterisation

— Volatiles, ash, Br, C, Cl, F, H, N, O, S


A.6 BAT 12: To increase the energy efficiency of combustion, gasificationand/or IGCC units operated ≥ 1 500 h/yr, BAT is to use an appropriatecombination of the techniques given below


Combustionoptimisation

See description in Section 8.2.Optimising the combustion minimises the content

of unburnt substances in the flue-gases and insolid combustion residues


b.

Optimisation ofthe working

mediumconditions

Operate at the highest possible pressure andtemperature of the working medium gas or steam,

within the constraints associated with, forexample, the control of NOX emissions or the

characteristics of energy demanded

c.

Optimisation ofthe steam cycle

Operate with lower turbine exhaust pressure byutilisation of the lowest possible temperature ofthe condenser cooling water, within the design

conditions

d.

Minimisation ofenergy

consumption

Minimising the internal energy consumption (e.g.greater efficiency of the feed-water pump)

e.

Preheating ofcombustion air

Reuse of part of the heat recovered from thecombustion flue-gas to preheat the air used in

combustion

Generally applicable within theconstraints related to the need to

control NOX emissions

f.

Fuel preheating Preheating of fuel using recovered heat Generally applicable within theconstraints associated with the boiler

design and the need to control NOX

emissions

g.

Advanced controlsystem

See description in Section 8.2.Computerised control of the main combustion

parameters enables the combustion efficiency tobe improved

Generally applicable to new units. Theapplicability to old units may be

constrained by the need to retrofit thecombustion system and/or control

command system

h.

Feed-waterpreheating using

recovered heat

Preheat water coming out of the steam condenserwith recovered heat, before reusing it in the boiler

Only applicable to steam circuits andnot to hot boilers.

Applicability to existing units may belimited due to constraints associated

with the plant configuration and theamount of recoverable heat

i.

Heat recovery bycogeneration

(CHP)

Recovery of heat (mainly from the steam system)for producing hot water/steam to be used inindustrial processes/activities or in a publicnetwork for district heating. Additional heat

recovery is possible from:

— flue-gas

— grate cooling

— circulating fluidised bed

Applicable within the constraintsassociated with the local heat and

power demand.The applicability may be limited in the

case of gas compressors with anunpredictable operational heat profile

j.

CHP readiness See description in Section 8.2. Only applicable to new units wherethere is a realistic potential for the

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Technique Description Applicabilityfuture use of heat in the vicinity of the

unit

k.

Flue-gascondenser

See description in Section 8.2. Generally applicable to CHP unitsprovided there is enough demand for

low-temperature heat

l.

Heataccumulation

Heat accumulation storage in CHP mode Only applicable to CHP plants.The applicability may be limited in the

case of low heat load demand

m.

Wet stack See description in Section 8.2. Generally applicable to new andexisting units fitted with wet FGD

n.

Cooling towerdischarge

The release of emissions to air through a coolingtower and not via a dedicated stack

Only applicable to units fitted with wetFGD where reheating of the flue-gas is

necessary before release, and wherethe unit cooling system is a cooling

tower

o.

Fuel pre-drying The reduction of fuel moisture content beforecombustion to improve combustion conditions

Applicable to the combustion ofbiomass and/or peat within the

constraints associated withspontaneous combustion risks (e.g. themoisture content of peat is kept above

40 % throughout the delivery chain).The retrofit of existing plants may berestricted by the extra calorific valuethat can be obtained from the drying

operation and by the limited retrofitpossibilities offered by some boiler

designs or plant configurations

p.

Minimisation ofheat losses

Minimising residual heat losses, e.g. those thatoccur via the slag or those that can be reduced by

insulating radiating sources

Only applicable to solid-fuel-firedcombustion units and togasification/IGCC units

q.

Advancedmaterials

Use of advanced materials proven to be capableof withstanding high operating temperatures and

pressures and thus to achieve increasedsteam/combustion process efficiencies

Only applicable to new plants

r.

Steam turbineupgrades

This includes techniques such as increasing thetemperature and pressure of medium-pressuresteam, addition of a low-pressure turbine, and

modifications to the geometry of the turbine rotorblades

The applicability may be restricted bydemand, steam conditions and/or

limited plant lifetime

s.

Supercritical andultra-supercriticalsteam conditions

Use of a steam circuit, including steam reheatingsystems, in which steam can reach pressures

above 220,6 bar and temperatures above 374 °Cin the case of supercritical conditions, and above

250 – 300 bar and temperatures above580 – 600 °C in the case of ultra-supercritical

conditions

Only applicable to new units of≥ 600 MWth operated > 4 000 h/yr.

Not applicable when the purpose of theunit is to produce low steam

temperatures and/or pressures inprocess industries.

Not applicable to gas turbines andengines generating steam in CHP

mode.For units combusting biomass, theapplicability may be constrained by

high-temperature corrosion in the caseof certain biomasses

A.7 BAT 13: To reduce water usage and the volume of contaminated wastewater discharged, BAT is to use one or both of the techniques given below


Waterrecycling

Residual aqueous streams, including run-off water,from the plant are reused for other purposes. The

degree of recycling is limited by the quality

Not applicable to waste water fromcooling systems when water treatment

chemicals and/or high concentrations ofsalts from seawater are present

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Technique Description Applicabilityrequirements of the recipient water stream and the

water balance of the plant

b.

Dry bottomash

handling

Dry, hot bottom ash falls from the furnace onto amechanical conveyor system and is cooled down by

ambient air. No water is used in the process.

Only applicable to plants combustingsolid fuels.

There may be technical restrictions thatprevent retrofitting to existing combustion

plants

A.8 BAT 15: To reduce emissions to water from flue-gas treatment, BAT is touse an appropriate combination of the techniques given below, and to usesecondary techniques as close as possible to the source in order to avoiddilution

Technique Typical pollutantsprevented/abated

Applicability

Primary techniquesa.

Optimised combustion (seeBAT 6) and flue-gas treatmentsystems (e.g. SCR/SNCR, see

BAT 7)

Organic compounds,ammonia (NH3)


Secondary techniquesb.

Adsorption on activated carbon Organic compounds,mercury (Hg)


c.

Aerobic biological treatment Biodegradable organiccompounds, ammonium

(NH4 +)

Generally applicable for the treatment of organiccompounds. Aerobic biological treatment of

ammonium (NH4 +) may not be applicable inthe case of high chloride concentrations (i.e.

around 10 g/l)

d.

Anoxic/anaerobic biologicaltreatment

Mercury (Hg), nitrate(NO3 –), nitrite (NO2 –)


e.

Coagulation and flocculation Suspended solids Generally applicable

f.

Crystallisation Metals and metalloids,sulphate (SO4 2–),

fluoride (F–)


g.

Filtration (e.g. sand filtration,microfiltration, ultrafiltration)

Suspended solids, metals Generally applicable

h.

Flotation Suspended solids, free oil Generally applicable

i.

Ion exchange Metals Generally applicable

j.

Neutralisation Acids, alkalis Generally applicable

k.

Oxidation Sulphide (S2–), sulphite(SO3 2–)


l.

Precipitation Metals and metalloids,sulphate (SO4 2–),

fluoride (F–)


m.

Sedimentation Suspended solids Generally applicable

n.

Stripping Ammonia (NH3) Generally applicable

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A.9 BAT 16: Reduce the quantity of waste sent for disposal from thecombustion and/or gasification process and abatement techniques, BAT is toorganise operations so as to maximise, in order of priority and taking intoaccount life-cycle thinking


Generation ofgypsum as a by-

product

Quality optimisation of the calcium-based reactionresidues generated by the wet FGD so that they

can be used as a substitute for mined gypsum (e.g.as raw material in the plasterboard industry). The

quality of limestone used in the wet FGD influencesthe purity of the gypsum produced

Generally applicable within theconstraints associated with the

required gypsum quality, the healthrequirements associated to each

specific use, and by the marketconditions

b.

Recycling orrecovery of

residues in theconstruction

sector

Recycling or recovery of residues (e.g. from semi-dry desulphurisation processes, fly ash, bottom

ash) as a construction material (e.g. in roadbuilding, to replace sand in concrete production, or

in the cement industry)

Generally applicable within theconstraints associated with the

required material quality (e.g.physical properties, content of

harmful substances) associated toeach specific use, and by the market

conditions

c.

Energy recoveryby using waste in

the fuel mix

The residual energy content of carbon-rich ash andsludges generated by the combustion of coal,lignite, heavy fuel oil, peat or biomass can berecovered for example by mixing with the fuel

Generally applicable where plantscan accept waste in the fuel mix andare technically able to feed the fuels

into the combustion chamber

d.

Preparation ofspent catalyst for

reuse

Preparation of catalyst for reuse (e.g. up to fourtimes for SCR catalysts) restores some or all of the

original performance, extending the service life ofthe catalyst to several decades. Preparation of

spent catalyst for reuse is integrated in a catalystmanagement scheme

The applicability may be limited bythe mechanical condition of the

catalyst and the requiredperformance with respect to

controlling NOX and NH3 emissions

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A.10 BAT 17: In order to reduce noise emissions, BAT is to use one or acombination of the techniques given below


Operationalmeasures

These include:

— improved inspection and maintenance ofequipment

— closing of doors and windows of enclosedareas, if possible

— equipment operated by experienced staff

— avoidance of noisy activities at night, ifpossible

— provisions for noise control duringmaintenance activities


b.

Low-noiseequipment

This potentially includes compressors, pumpsand disks

Generally applicable when theequipment is new or replaced

c.

Noise attenuation Noise propagation can be reduced by insertingobstacles between the emitter and the receiver.Appropriate obstacles include protection walls,

embankments and buildings

Generally applicable to new plants. Inthe case of existing plants, the insertionof obstacles may be restricted by lack of

space

d.

Noise-controlequipment

This includes:

— noise-reducers

— equipment insulation

— enclosure of noisy equipment

— soundproofing of buildings

The applicability may be restricted bylack of space

e.

Appropriatelocation of

equipment andbuildings

Noise levels can be reduced by increasing thedistance between the emitter and the receiver

and by using buildings as noise screens

Generally applicable to new plants. Inthe case of existing plants, the relocation

of equipment and production units maybe restricted by lack of space or by

excessive costs

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mottmac.com

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